SEC Comment Letter for PLANTRONICS — Apr 6, 2020
PLANTRONICS INC /CA/ (CIK 0000914025)
Date: April 6, 2020 · CIK: 0000914025 · Accession: 0000000000-20-002949
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File numbers found in text: 001-12696
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April 3, 2020
Charles Boynton
Chief Financial Officer
Plantronics, Inc.
345 Encinal Street
Santa Cruz, CA 95060
Re:Plantronics, Inc.
Form 10-K for the Fiscal Year Ended March 30, 2019
Filed May 17, 2019
File No. 001-12696
Dear Mr. Boynton:
We have reviewed your March 10, 2020 response to our comment letter and have the
following comment. In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
February 12, 2020 letter.
Form 10-K for the Fiscal Year Ended March 30, 2019
Financial Statements and Supplementary Data
Notes to Consolidated Financial Statements
Note 1. Company , page 62
1.Consistent with the information discussed on our telephone call of April 2, 2020, please
provide us with a sufficiently detailed summary of the key changes to your business and
your assessment of the impact to your fiscal year 2020 reporting, including your operating
and reportable segments as well as the reporting units used in your impairment
analysis. Clearly identify all changes you expect to reflect in your Form 10-K for the
fiscal year ended March 28, 2020.
FirstName LastNameCharles Boynton
Comapany NamePlantronics, Inc.
April 3, 2020 Page 2
FirstName LastName
Charles Boynton
Plantronics, Inc.
April 3, 2020
Page 2
You may contact Dale Welcome at 202-551-3865 or Martin James, Senior Advisor, at
202-551-3671 if you have questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing